ID: aiam1963

Dear Mr. Walters: This is in response to your letter requesting information concernin standards that relate to the construction of a pick-up camper.; Although your letter is unclear on this point, we assume that you questions relate to the building of a single slide-in camper for your own use. If this is the case, the only standards with which you must comply are Standard No. 126, *Truck-camper loading*, and Standard No. 205, *Glazing materials*. In addition, your camper should be certified in accordance with 49 CFR Part 567.; The NHTSA can provide no information concerning methods of constructio of these or other items of motor vehicle equipment.; Yours truly, Richard B. Dyson, Assistant Chief Counsel

ID: aiam3831

Dear Mr. McMillan: This is in response to your March 5, 1984 letter regarding the exten to which an automotive remote starting device which one of your clients wishes to market is compatible with the requirements of Federal Motor Vehicle Safety Standard (FMVSS) 114, *Theft Protection*. This device would permit a vehicle to be started from a remote location using a signal transmitter, provided the vehicle's gear shift is in the park position, the emergency brake is set, the hood is closed, and all the vehicle doors are closed. Further, should any of these failsafe systems become deactivated (e.g., gear shift level moved out of the park position), the engine would automatically shut off.; FMVSS 114 requires that passenger cars as well as trucks an multipurpose passenger vehicles with a gross vehicle weight rating of 10,000 pounds or less must have a key locking system that, when the key is removed, will prevent normal activation of the vehicle's engine and either steering or forward self-mobility. We presume that the steering/transmission lock feature is unaffected by your client's device. Therefore, the question presented by your client's system is whether that device, which permits activation of the engine when the ignition key is removed, permits 'normal activation' of the vehicle.; In a previous agency interpretation (copy enclosed), the agenc described certain characteristics of a remote starting system similar to your client's which we concluded were outside the concept of 'normal activation.' These characteristics were automatic deactivation of the remotely started engine when a vehicle door is opened, maintenance of the steering column or gear shift locking feature until the ignition key is inserted in the vehicle, and automatic deactivation of the remotely started engine after 15 minutes (unless the key is inserted in the ignition).; Your client's device apparently has some of these same characteristic as this previously considered device, as well as other automatic engine deactivation features which are comparable in nature. Therefore, we conclude your client's device does not conflict with the requirements of FMVSS 114, since it does not permit normal activation of the engine without the ignition key.; Sincerely, Frank Berndt, Chief Counsel

ID: aiam0316

Dear Mr. Martens:#This is in reply to your letter of March 23, 1971 t Mr. Rodolfo A. Diaz about the combined windshield wiper-washer control symbol and the 'upright position' requirement as applied to this control identification.#The symbol combining the wiper and washer symbols as illustrated in your letter is approved for identifying the combined wiper- washer control.#The symbol placement on the combined wiper-washer control which you propose is in accordance with the intent of S4.2, since it appears upright to the driver in the 'off' position.#We appreciate your writing to us. If we can be of further service, please let us know.#Sincerely, E. T. Driver, Director, Office of Operating Systems, Motor Vehicle Programs;

ID: aiam0757

Dear Mr. Nishibori: This is in reply to your letter of June 9, 1972, concerning th proposed amendment to paragraph S4.2 of Motor Vehicle Safety Standard No. 302 (36 F.R. 9565, May 26, 1971). As we understand your question it is, when surface, underlying, or padding and cushioning materials are glued together in particular vehicle components, should you test with the glue applied to the contact points between the materials.; The proposed revision of paragraph S4.2 together with paragraph S5. o the standard contemplates the testing of composites with the individual materials joined together, as they appear in the vehicle. Materials glued together would be tested in that configuration during NHTSA compliance tests, and the glue would be tested as part of the composite.; Yours truly, Richard B. Dyson, Assistant Chief Counsel

ID: 1985-01.49

TYPE: INTERPRETATION-NHTSA

DATE: 03/15/85

FROM: AUTHOR UNAVAILABLE; Jeffrey R. Miller; NHTSA

TO: Mr. M. Iwase

TITLE: FMVSS INTERPRETATION

TEXT:

March 15, 1985 Mr. M. Iwase Manager, Technical Administration Dept. Koito Manufacturing Co., Ltd. Shizuoka Works 500, Kitawaki Shimizu-shi, Shizuoka-ken Japan Dear Mr. Iwase: This is in reply to your letter of February 1, 1985, with reference to the compliance with Motor Vehicle Safety Standard No. 108 of a proposed motorcycle headlamp design. In the design shown in your letter a single housing would contain two dual-filament bulbs, each with an independently aimed reflector. You have stated that the headlamp can comply with the photometric requirements of Sae J584 when either compartment is lit, and that the assembly will meet all other requirements of J584. A dual bulb arrangement in a single housing is considered a single headlamp, and therefore its compliance will be judged when both compartments are lit to provide either the upper or lower beam. Assuming that when both compartments are lit the combined candlepower at individual test points does not exceed the maxima imposed by J584 for those test points, your design appears to comply with Standard No. 108. Sincerely, Original Signed By Jeffrey R. Miller Chief Counsel

ID: aiam2766

Dear Mr. Wood: This responds to your January 16, 1978, letter asking several question about the applicability of the school bus regulations to school buses manufactured after April 1, 1977, transporting 10 or more students to or from school or related events.; You first ask whether these buses must be painted yellow and hav school bus lighting and markings. The answer to your question is yes. Any vehicle that transports 10 or more students to or from school or related events is a school bus and must have the painting, marking, and lighting of a school bus.; Your second question is whether smaller school buses (vans) ar permitted to have van-type seats or must comply with the requirements of Standard No. 222, *School Bus Passenger Seating and Crash Protection*. A vehicle that transports 10 or more students must comply with all of the Federal school bus regulations, including the seating standard.; Sincerely, Joseph J. Levin, Jr., Chief Counsel

ID: aiam2246

Dear Mr. Kirwan: This is in response to your letter of February 25, 1976, requestin information concerning the Federal motor vehicle safety standards and regulations applicable to transit vehicles, specifically, Dodge vans that will be used in a rural transportation system.; The answers to your questions are as follows: >>>(1) 'Which FMVSS apply to vans used in transit service?'<<< If your Dodge vans are designed to carry 10 persons or less they woul qualify as 'multipurpose passenger vehicles', as defined in 49 CFR Part 571.3. As multipurpose passenger vehicles, the Dodge vans would be subject to the requirements of the Federal Motor Vehicle Safety Standards listed below. The standards marked with an asterisk (*) are equipment standards and do not apply to the vehicles themselves. Rather, these standards set forth requirements for manufacturers of motor vehicle equipment for use in multipurpose passenger vehicles.; >>>No. 101 - *Control Location, Identification, and Illumination.* No. 102 - *Transmission Shift Lever Sequence, Starter Interlock, an Transmission Braking Effect*.; No. 103 - *Windshield Defrosting and Defogging Systems*. No. 104 - *Windshield Wiping and Washing Systems*. *No. 106-74 - *Brake Hoses*. No. 107 - *Reflecting Surfaces*. No. 108 - *Lamps, Reflective Devices, and Associated Equipment.* No. 111 - *Rearview Mirrors.* No. 112 - *Headlamp Concealment Devices*. No. 113 - *Hood Latch System.* *No. 116 - *Motor Vehicle Brake Fluids.* No. 118 - *Power Operated Window Systems*. *No. 119 - *New Pneumatic Tires for Vehicles Other Than Passenge Cars.*; No. 120 - *Tire Selection and Rims for Vehicles Other than(sic Passenger Cars*.; No. 124 - *Accelerator Control Systems*. *No. 125 - *Warning Devices*. *No. 205 - *Glazing Materials*. No. 206 - *Door Locks and Door Retention Components.* No. 207 - *Seating Systems*. No. 208 - *Occupant Crash Protection.* *No. 209 - *Seat Belt Assemblies*. No. 210 - *Seat Belt Assembly Anchorages*. No. 211 - *Wheel Nuts, Wheel Discs and Hub Caps*. No. 213 - *Child Seating Systems*. No. 219 - *Windshield Zone Intrusion*. No. 301-75 - *Fuel System Integrity*. No. 302 - *Flammability of Interior Materials*.<<< The manufacturer of the Dodge vans must affix a label to each vehicl certifying that the vehicle is in compliance with all applicable Federal motor vehicle safety standards and regulations, as required by 49 CFR Part 567, *Certification.* This certification label should be affixed to the door or door post of each vehicle, and you should check to make certain that it is present.; Please note that if the Dodge vans are designed to carry more than 1 persons, they would be classified as 'buses' under 49 CFR Part 567.3, and the list of applicable safety standards would differ.; >>>(2) 'Does NHTSA recommend a set of vehicle specifications for van used in transit?'<<<; No. The NHTSA has issued only the requirements found in the moto vehicle safety standards and regulations.; >>>(3) 'Do any FMVSS apply specifically to modified vans (e.g. thos filled with hydraulic lift for wheelchairs and a raised roof)?'<<<; No. Such vehicles must meet the same standards as other MPV's. >>>(4) 'Are there any regulations which apply to fiberglass bubbletop on vans in transit service?'<<<; Yes. Motor Vehicle Safety Standard No. 205, *Glazing Materials,* 49 CF 571.205, specifies requirements for glazing materials for use in motor vehicles and motor vehicle equipment. Rigid plastic materials that are to be used as covers for openings in the roof of a vehicle must conform to the requirements specified in paragraph S5.1.2.1 of Standard No. 205.; >>>(5) 'Are there any regulations, perhaps within the Federal Highwa Safety Act, which apply to driver qualifications?'<<<; Yes. Driver qualifications for transit vehicles are governed by Federa Motor Carrier Safety Regulations, 49 CFR Part 391, *Qualifications of Drivers*.; >>>(6) 'Could you provide any further information which you feel woul contribute to the safe operation of our transit system?'<<<; At the present time the NHTSA has not issued any general guideline concerning the organization or operation of transit systems. You may, however, wish to contact the Urban Mass Transportation Administration of this Department for information on this subject.; I hope this letter has been responsive to your questions. Pleas contact us if we can (sic) of any further assistance.; Yours truly, Richard B. Dyson, Assistant Chief Counsel

ID: aiam2036

Dear Mr. Hildebrandt: #This responds to your letter of July 14, 1975 requesting an interpretation of the labeling requirements of Federal Motor Vehicle Safety Standard No. 106-74, *Brake Hoses*, as applied to brake hose end fittings. #S5.2.3 of the standard requires (with an exception not relevant here) that one component of a multi-piece end fitting be labeled with certain information. You have pointed out that many end fittings designated for use with nylon brake hose include components identical to those found in fittings used with copper tubing, which is not covered by the standard. Labeling of one of these common components would satisfy the standard. You have interpreted Standard No. 106-74 as permitting an end fitting manufacturer to label his full stock of such components, even though some of them would appear in copper tubing assemblies. Your interpretation is correct. #Sincerely, Frank A. Berndt, Acting Chief Counsel;

ID: aiam2746

Dear Mr. Tydings: This responds to your December 8, 1977, letter asking for a interpretation of the term 'passenger compartment' as used by the National Highway Traffic Safety Administration (NHTSA) in Standard No. 217, *Bus Window Retention and Release*.; Standard No. 217 requires that a school bus side emergency door b located in the rear half of the bus passenger compartment. The NHTSA interprets the term 'passenger compartment' to mean the area from the windshield to the back of the bus.; In a companion question, you ask whether it would be permissible for small portion of a side emergency door, installed pursuant to S5.2.3.1(b), to fall within the front half of a bus as long as most of the door is within the required rear half of the passenger compartment. The answer to your question is no. The emergency door must be totally located within the rear half of the passenger compartment.; Sincerely, Joseph J. Levin, Jr., Chief Counsel

ID: aiam2202

Dear Mr. Crampton: This is in response to your letter of January 16, 1976, concerning cre cab doors for use on fire trucks, and the interpretation of Federal Motor Vehicle Safety Standard No. 206, *Door Locks and Door Retention Components*.; You asked two questions in your letter: >>>(1) Is it the intent of FMVSS 206 to actually address door hardwar for doors that are adjacent to a walkway and not a seat?<<<; Standard No. 206 is applicable to the type of vehicle that yo described. Paragraph S4 of the standard states that 'component on any side door leading directly into a compartment that contains one or more seating accommodations shall conform to this standard'. The standard does not require the door to be directly adjacent to a seat. The door on your vehicle leads directly 'into a compartment that contains one or more seating accommodations,' so the standard is applicable. The presence of a walkway is irrevelant. (sic); >>>(2) If the standard does apply would not the installation of a untested conventional door structure in place of a folding door result in a safer vehicle?<<<; The NHTSA hopes that manufacturers would install conventional hinge door structures instead of folding doors on fire trucks, if the hinged doors would result in producing safer vehicles. The cost of testing the components of hinged doors for purposes of Standard 206 should not be determinative of whether the manufacturer will install hinged doors or folding doors on the fire trucks. Rather, the safety of the firemen who must use the trucks should be the determinative factor.; You should be aware that the tests in Standard No. 206 are laborator tests of the components, and do not involve the vehicle as a whole. These component systems are generally available from suppliers and are already warranted as being in compliance with Federal standards. Therefore, the cost of using conventional hinged doors might not be as prohibitive as you had supposed.; Please contact us if we can be of any further assistance. Yours truly, Richard B. Dyson, Assistant Chief Counsel